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Pennsylvania Court finds that a worker injured after quitting was entitled to workers’ comp benefits

In a recent Pennsylvania case, an employee who was injured after quitting his job was eligible for workers’ compensation benefits.

Yahoo News reports that Pennsylvania employers can significantly reduce their workers’ compensation insurance premiums by setting up certified workplace safety committees. The goal of such safety committees is to detect workplace hazards and prevent workplace accidents and illnesses from occurring. While these employer safety programs are certainly laudable, no workplace can be made perfectly safe.

Broadly speaking, an employee is eligible for workers’ compensation benefits if a work-related injury occurs while the employee is furthering the interest of his or her employer. Typically, if someone is injured after they either quit their job or were fired, the worker is not entitled to workers’ compensation benefits. However, there can be instances where a person is eligible for benefits even after their employment ends.

The Marazas case

In the recent case of Marazas v. W.C.A.B. (Vitas Healthcare Corp), the court reviewed an order of the Workers’ Compensation Appeal Board (Board), which reversed an award of benefits to the claimant by the workers’ compensation judge (WCJ).

In the Marazas case, the claimant was a driver-technician who delivered and picked up medical equipment. Following a weekend when the claimant was on-call, he reported for work to receive his daily itinerary. After learning it would take him until midnight to complete his tasks, he complained to his manager and requested that some stops be removed from his itinerary. The manager refused and the disgusted claimant turned in his keys and announced he was quitting. The manager informed him he needed to remove his personal belongings from the company truck and then escorted him to the truck. After removing items from the truck as directed, the claimant tripped over a pallet jack while on his former’s employer’s premises.

The claimant alleged that he sustained work-related injuries to his left ankle and left knee as well as significant lower back pain. The WCJ found that the claimant was entitled to workers’ compensation benefits even though he had quit his job just prior to his injury. The reasoning of the WCJ was that the claimant was acting within the scope of employment-and in furtherance of his employer’s interest-when injured. The Board reversed the WCJ and reasoned that the claimant was not acting within the course and scope of employment at the time of his injury because he quit before he tripped and fell. The claimant appealed the Board’s decision to the Commonwealth Court of Pennsylvania.

The court observed that there was no dispute that the claimant’s injury occurred on the employer’s premises. Further, by removing his belongings from the employer’s truck under the manager’s supervision, the claimant was furthering the employer’s interests. Indeed, he was acting under the manager’s direct supervision while cleaning out the truck and was therefore under the employer’s control at the time the injury occurred. According to the court, if the claimant is acting in furtherance of the employer’s affairs, the mere termination of the employment relationship does not automatically operate to bar workers’ compensation benefits. Consequently, the Board’s order was reversed and the WCJ’s order granting the claimant benefits was reinstated.

Seeking compensation

If you have sustained a workplace injury, you should immediately contact a Pennsylvania attorney experienced in handling workers’ compensation claims. An employee’s entitlement to benefits is sometimes strongly contested by employers. An attorney will investigate the facts of your situation and determine your best course of action.